[ONLINE] Relief from Double Taxation – 14 March

This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:

  • Economic double taxation (EDT) relief:
    • Rationale & types of EDT relief;
    • EDT relief mechanisms in the ITA;
      • The full imputation system (article 31, 59 and 60 of the ITA);
      • The participation exemption (as relevant for the relief of EDT); and
      • The indirect foreign tax credit.
    • Juridical double taxation relief:
      • Rationale & types of JDT relief;
        • Outbound considerations:
          • Ordinary direct foreign tax credit system;
          • Treaty relief
          • Unilateral relief
          • Commonwealth relief;
          • Flat-rate foreign tax credit.
          • The participation exemption (as relevant for the relief of JDT).
        • Inbound considerations:
          • Source rules;
          • Treaty relief as applicable to Malta as the ‘other Contracting State’.
        • Miscellaneous issues:
          • Switch-over clauses;
          • Anti-hybrid rules;
          • Subject-to-tax rules.

Instructed by: Dr Christopher Bergendahl. in:

Seminar Description

Seminar Description

This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:

  • Economic double taxation (EDT) relief:
    • Rationale & types of EDT relief;
    • EDT relief mechanisms in the ITA;
      • The full imputation system (article 31, 59 and 60 of the ITA);
      • The participation exemption (as relevant for the relief of EDT); and
      • The indirect foreign tax credit.
    • Juridical double taxation relief:
      • Rationale & types of JDT relief;
        • Outbound considerations:
          • Ordinary direct foreign tax credit system;
          • Treaty relief
          • Unilateral relief
          • Commonwealth relief;
          • Flat-rate foreign tax credit.
          • The participation exemption (as relevant for the relief of JDT).
        • Inbound considerations:
          • Source rules;
          • Treaty relief as applicable to Malta as the ‘other Contracting State’.
        • Miscellaneous issues:
          • Switch-over clauses;
          • Anti-hybrid rules;
          • Subject-to-tax rules.

CPE

Qualifies for 3 CPE Core hours under the core competency area.

Seminar Fee

The seminar fee is Non Member €70.00, Members €60.00. The fee covers seminar participation and access to event resources.

A receipt will be issued to all participants.

Event Resources

Participants will receive the event resources by email.

Additional Information

For more information, kindly use the following communication mediums:

T: 21 58 53 74   M: 77 01 17 19   E: info@skillsmalta.com      Webpage: www.skillsmalta.com